The OECD has released two new documents to support the implementation of country by country (CBC) reporting by tax administrations and multinational groups (BEPS Action 13). These are:
· country-specific information giving key details of jurisdictions’ domestic legal frameworks; and
· additional interpretive guidance on filing and reporting during the transitional phase.
The details on jurisdictions’ legal frameworks for CBC reporting include the status of the legislation, first reporting periods, availability of surrogate filing and voluntary filing, and whether local filing can be required.
The additional guidance relates to the case where a notification to the tax administration may be required to identify the reporting entity within a multinational group. The guidance confirms that if such notifications are required, jurisdictions have flexibility as to the due date. This may be particularly relevant during the transition period where jurisdictions are still completing their implementation of CBC reporting, as multinational groups may not yet have the necessary information to submit their notifications. The guidance also confirms that jurisdictions may wish to consider other transitional relief for multinational groups with respect to these notifications, which would also be consistent with the minimum standard.
The OECD has released two new documents to support the implementation of country by country (CBC) reporting by tax administrations and multinational groups (BEPS Action 13). These are:
· country-specific information giving key details of jurisdictions’ domestic legal frameworks; and
· additional interpretive guidance on filing and reporting during the transitional phase.
The details on jurisdictions’ legal frameworks for CBC reporting include the status of the legislation, first reporting periods, availability of surrogate filing and voluntary filing, and whether local filing can be required.
The additional guidance relates to the case where a notification to the tax administration may be required to identify the reporting entity within a multinational group. The guidance confirms that if such notifications are required, jurisdictions have flexibility as to the due date. This may be particularly relevant during the transition period where jurisdictions are still completing their implementation of CBC reporting, as multinational groups may not yet have the necessary information to submit their notifications. The guidance also confirms that jurisdictions may wish to consider other transitional relief for multinational groups with respect to these notifications, which would also be consistent with the minimum standard.
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